Trade Groups Support CFTC-Proposed Amendments To Uncleared Swap Margin Rules

In comments responding to recent CFTC-proposed amendments to the uncleared swap margin requirements, ISDA, the Global Foreign Exchange Division ("GFXD"), SIFMA, SIFMA's Asset Management Group, the Investment Company Institute, the Managed Funds Association ("MFA"), FIA and the American Council for Life Insurers ("ACLI") expressed support for the proposals (see here and here). The groups also offered recommendations to enhance the proposals to further their intended impact.

As previously covered, the CFTC proposed changes related to initial margin ("IM"), including with regard to (i) determinations of the calculation period for whether IM requirements apply and (ii) certain swap dealers ("SDs") being permitted to rely on models used by SD counterparties for limited purposes (the "IM proposal"). The CFTC also proposed to codify prior no-action relief related to the application of rules on minimum transfer amounts ("MTA") (the "MTA proposal").